Assess whether a model update needs a fair-lending revalidation (bdfa93)

Situation

Second-review underwriter owns a model update needs inside a lender expanding into majority-minority census tracts with credit-card limit assignment disparity table as the only packet. A marketing mailer that skipped majority-minority tracts is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a marketing mailer that skipped majority-minority tracts for second-review underwriter.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: second-review underwriter does not have the page a model update needs turns on in credit-card limit assignment disparity table.

Analysis required

• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a model update needs for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for second-review underwriter in a lender expanding into majority-minority census tracts.